As regulators across Europe, the United Kingdom, Switzerland and the United Arab Emirates refine their approaches to cross-border fund distribution, investment managers are navigating a fresh wave of supervisory adjustments, legal clarifications and rising regulatory costs.
A recent report from Zeidler Group delves into the recent regulatory and fee changes across Europe, the UK, Switzerland and the UAE.
The latest changes span structural reforms at supervisory authorities, new cross-border exemptions, updated disclosure expectations and revised fee schedules. Collectively, they highlight a regulatory environment that is becoming more precise in scope while also more demanding in operational terms.
In the United Arab Emirates, the authority formerly known as the Securities and Commodities Authority has formally rebranded as the Capital Markets Authority (CMA), effective 1 January 2026. The name change is part of a broader restructuring of the country’s capital markets framework and is now reflected across official materials and guidance, Zeidler said.
Alongside the rebranding, the CMA has introduced two Federal Decree Laws. The first (FLD32) addresses the establishment and powers of the CMA, while the second (FLD33) sets out the overarching regulatory framework for capital markets.
Importantly for global fund managers, Zeidler said, FLD33 clarifies that foreign funds marketed to UAE investors fall within the scope of UAE regulation, irrespective of where the marketing activity physically takes place. The decree reinforces the need for regulatory approval before offering foreign funds onshore and strengthens the authority’s supervisory and enforcement toolkit.
Meanwhile, the United Kingdom and Switzerland have moved in the opposite direction by introducing a mutual recognition model under the Berne Financial Services Agreement (BFSA), which came into force on 1 January 2026. The agreement establishes a framework permitting Swiss and UK investment firms to provide certain services to wholesale and sophisticated clients on a cross-border basis without triggering full host-state authorisation requirements.
Firms seeking to rely on the exemption must be authorised in their home jurisdiction and included on the relevant BFSA register. The agreement is underpinned by a recognition that both countries operate regulatory regimes of comparably high standards. In practical terms, this means firms may defer to their home-country supervisory rules rather than duplicating compliance with host-country frameworks, it said.
In Iceland, regulators have taken a more nuanced approach to disclosure requirements. Updated guidance published in September 2025 addresses the language obligations for PRIIPs Key Information Documents (KIDs). Under certain conditions, KIDs may now be provided in English. Circular No. 19/2025 confirms that English-language documents are acceptable where the distributor ensures that investors understand the product’s key features and risks and that other legal requirements, such as target market definitions, are met.
However, where a product is marketed in Iceland or in Icelandic, an Icelandic-language KID must also be supplied. In cases of reverse solicitation, where the product is not marketed locally and the investor initiates the request, an English-only KID may suffice provided the other conditions are satisfied.
For more insights into changes around the world, read the full story here.
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